Difference Between Mainland Georgia VASP vs Tbilisi Free Zone Crypto License

Georgia has quietly become one of the most compelling destinations in the world for crypto entrepreneurs and fintech founders. Strategically positioned at the crossroads of Europe and Asia, the country combines low operational costs, a business-friendly government, and a rapidly maturing regulatory environment into a package that few jurisdictions can match.

The landmark moment came on July 1, 2023, when the Law on Virtual Asset Service Providers (VASPs) came into force, bringing long-awaited regulatory clarity to the Georgian crypto sector. For the first time, businesses could obtain a formally recognised crypto license in Georgia, backed by a clear legal framework and supervised by a credible national regulator.

For entrepreneurs, however, the key question is not simply whether to incorporate in Georgia, but which structure to choose. There are two distinct pathways: the mainland Georgia VASP license and the Tbilisi Free Industrial Zone (FIZ) crypto license. Each carries its own regulatory requirements, permitted activities, tax profile, and strategic use case. LegalBison helps fintech companies navigate this choice and handles the end-to-end process of global company formation and licensing in Georgia.

What is the mainland Georgia VASP license?

The mainland Georgia VASP license is the primary regulated authorisation for crypto businesses operating under the supervision of the National Bank of Georgia (NBG). It was introduced under the 2023 VASP Law and represents Georgia’s formal alignment with international standards for virtual asset service providers.

The VASP license permits a broad range of crypto activities directed at both Georgian residents and international clients. Permitted activities include:

• Crypto-to-fiat and fiat-to-crypto exchange services;
• Custodial wallet services, where the licensee holds private keys on behalf of clients;
• Token issuance, including initial token offerings (ITOs) and initial coin offerings (ICOs);
• Crypto lending platforms;
• Crypto trading platforms and brokerage services.

To obtain a Georgia VASP license, applicants must meet meaningful substance requirements. The business must maintain a physical office in Georgia. At least one director or authorised representative must spend a minimum of 14 days per month in the country, demonstrating genuine operational presence rather than a shell structure. A qualified compliance officer responsible for AML and KYC obligations must also be in place before the license is granted.

On the tax side, Georgia operates an Estonian-style corporate profit tax model. Corporate profits are not taxed at the point of accrual. Tax at a rate of 15% applies only when profits are distributed as dividends, making this a highly efficient structure for businesses that reinvest earnings into growth.

What is the Tbilisi Free Zone (FIZ) crypto license?

The Tbilisi Free Industrial Zone is a designated special economic zone that offers a fundamentally different value proposition. Rather than a regulatory license issued by the NBG, the FIZ authorisation is granted by the zone administration and is designed specifically for internationally focused operations.

The Tbilisi FIZ crypto license is well-suited to businesses that operate on a business-to-business (B2B) basis and serve clients outside Georgia. Permitted activities within the FIZ include:

• Crypto-to-crypto exchange services;
• Digital asset storage and custody for international clients;
• Cryptocurrency mining operations.

There is one important limitation that founders must understand clearly: FIZ companies cannot offer fiat-to-crypto exchange services, manage third-party funds in fiat currency, or provide regulated financial services directly to Georgian residents. If your business model requires serving local Georgian clients or handling fiat currency on behalf of users, the FIZ structure is not the appropriate route.

The tax benefits of the Georgia FIZ are among the most generous of any crypto jurisdiction globally. Qualifying companies benefit from 0% corporate profit tax, 0% VAT, and 0% property tax, provided their activities are directed at non-Georgian clients. This makes the FIZ exceptionally attractive for mining operations, international B2B crypto infrastructure businesses, and crypto-to-crypto trading platforms serving a global user base.

Setup is also notably faster than the mainland route. A FIZ authorisation can typically be obtained within two to three weeks, compared to one and a half to two months for a full NBG VASP license.

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Head-to-head: Georgia vs Tbilisi Free Zone crypto license

Choosing between the two structures comes down to a careful analysis of your business model, target market, and tax priorities. The table below summarises the principal differences:

Both the mainland VASP license and the Tbilisi FIZ crypto license sit within Georgia’s broader ecosystem of crypto-friendly regulation, which has made the country a preferred destination among the top crypto license jurisdictions worldwide. Businesses looking at alternative low-tax structures elsewhere may also wish to review LegalBison’s overview of offshore crypto license options as a point of comparison.

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Legal aspects and compliance for fintechs

Regardless of which route you choose, compliance obligations in Georgia are substantive and must be taken seriously. The Georgian regulatory framework aligns closely with FATF recommendations, and both NBG-licensed VASPs and FIZ entities serving international clients are expected to implement robust AML and KYC programmes.

For mainland VASP licensees, mandatory compliance obligations include:

• Full customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk clients;
• Ongoing transaction monitoring and the filing of suspicious transaction reports (STRs) to the Financial Monitoring Service (FMS) of Georgia;
• Implementation of the FATF Travel Rule, requiring VASPs to collect and transmit originator and beneficiary information for qualifying transfers;
• Maintenance of comprehensive records of all customer data and transactions for a minimum period as prescribed by Georgian law.

Directors and ultimate beneficial owners (UBOs) of both VASP and FIZ entities must also satisfy fit-and-proper requirements. This means clean criminal records, no history of financial fraud or regulatory sanctions, and the ability to demonstrate the professional competence expected of those managing a regulated financial services business.

These requirements are not merely procedural. Georgian regulators and, crucially, Georgian banks apply genuine scrutiny to crypto license applicants. A poorly drafted AML policy, an incomplete corporate structure, or a director who does not meet fit-and-proper criteria can delay or derail a license application entirely.

This is where professional legal assistance makes a tangible difference. LegalBison provides end-to-end support covering company registration, AML policy drafting, local director sourcing where required, and corporate bank account opening for fintech businesses entering the Georgian market. Our team understands what the NBG and the FIZ administration expect to see, and we structure applications to meet those expectations from the outset.

Conclusion

Georgia offers two genuinely attractive pathways for crypto entrepreneurs, but they serve different purposes and suit different business models.

The mainland Georgia VASP license is the right choice for businesses that need to offer the full spectrum of crypto financial services, including fiat-to-crypto exchange, custodial wallets, token issuance, and lending, whether to Georgian residents or international clients. It requires more substance, takes longer to obtain, and carries a 15% tax on distributed profits, but it provides the broadest regulatory permissions and the strongest institutional credibility.

The Tbilisi FIZ crypto license is the right choice for internationally focused operations, particularly mining businesses, crypto-to-crypto trading platforms, and B2B crypto infrastructure companies that serve non-Georgian clients and want to benefit from Georgia’s most favourable tax conditions. The 0% corporate profit tax and accelerated setup timeline make it a highly efficient structure for the right business model.

Choosing the wrong structure is a costly mistake. Operating activities that are not permitted under your license, or failing to meet substance and compliance requirements, create legal exposure that can be difficult and expensive to resolve after the fact.

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FAQ

What is the difference between a Georgia VASP and a FIZ crypto license? 

The Georgia VASP license is issued by the National Bank of Georgia and permits a full range of virtual asset services, including fiat-to-crypto exchange and custodial wallets, for both domestic and international clients. The FIZ license is issued by the Tbilisi Free Industrial Zone administration and is limited to crypto-to-crypto exchange, asset storage, and mining for non-Georgian clients, but benefits from 0% corporate profit tax.

Can a Tbilisi Free Zone company offer fiat-to-crypto exchange services? 

No. FIZ companies are not authorised to offer fiat-to-crypto exchange services or to manage client funds in fiat currency. Businesses requiring fiat-related services must obtain the mainland NBG VASP license.

What are the tax benefits of a Free Industrial Zone in Georgia? 

FIZ companies serving non-Georgian clients benefit from 0% corporate profit tax, 0% VAT, and 0% property tax. These exemptions make the FIZ one of the most tax-efficient structures available to crypto businesses globally.

What are the legal requirements for a National Bank of Georgia (NBG) VASP license? 

Applicants must establish a physical office in Georgia, appoint a qualified AML/compliance officer, and ensure that at least one director or authorised representative is physically present in Georgia for a minimum of 14 days per month. Directors and UBOs must satisfy fit-and-proper requirements, including a clean criminal record and demonstrable professional competence.